Preventive detention review is limited to procedural safeguards, and subjective satisfaction stands when supported by relevant material.

Preventive detention under COFEPOSA was tested only for compliance with constitutional and procedural safeguards, not by reappraising the detaining authority's subjective satisfaction. The Court noted that limited judicial review under Article 226 extends to checking whether Article 22 safeguards and other procedural requirements were observed, and found sufficient material supporting detention, including statements recorded under Section 108 of the Customs Act and the Advisory Board's opinion. The arguments based on no recovery, suspension from service, and alleged discrimination did not establish a legal infirmity. No ground for interference was made out, and the detention order was upheld.

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Issues: Whether the detention order under the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 suffered from any legal infirmity warranting interference in writ jurisdiction.

Analysis: The petition challenged the preventive detention order on grounds that there was no recovery, that suspension from service made detention unnecessary, and that the action was discriminatory. The Court held that preventive detention is based on the detaining authority's subjective satisfaction and that the scope of judicial review under Article 226 is limited to examining whether constitutional and procedural safeguards, including Article 22, have been complied with. The material placed before the detaining authority, including statements recorded under Section 108 of the Customs Act, 1962 and the opinion of the Advisory Board, showed sufficient grounds for detention. The suspension from service did not negate the other grounds recorded in support of detention, and no substantive procedural violation was shown.

Conclusion: No ground for interference was made out and the detention order was upheld.

Final Conclusion: The writ petition failed as the Court found no infirmity in the preventive detention order on the limited scope of judicial review.

Ratio Decidendi: In preventive detention matters, the Court interferes only on violation of constitutional or procedural safeguards, and not on reappraisal of the detaining authority's subjective satisfaction when supported by relevant material.

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